Thursday, March 06, 2008

Daniel Glaser is a deputy assistant secretary of the United States Treasury for terrorist financing and financial crimes. He also heads up the US delegation to the Financial Action Task Force.

On 28th February 2008, Complinet reported the latest finding of the FATF regarding Iran. Complinet has reported how the new finding has not altered the world advisory situation with regard to Iran from the previous finding in October 2007. International banks are still encouraged to apply enhanced due diligence when dealing with Iranian institutions.

Nevertheless, the FATF went to great pains to acknowledge that;

“…Since its October 2007 Plenary meeting, the FATF has engaged with Iran and welcomes the commitment made by Iran to improve its AML/CFT regime… Iran is encouraged to continue its engagement with the FATF and the international community to address, on an urgent basis, its AML/CFT deficiencies...”

The finding reflects the fact that the Iranians have taken significant steps to cooperate with the FATF, they have attended a meeting in Paris in January 2008 when they presented their AML programme to the representatives of the FATF, and answered a wide range of questions; that they have subsequently passed their first law dealing with AML issues, and that they have continued to liaise with the FATF, as requested.

The stated finding of the FATF is clear, unequivocal, and makes an open statement of their deliberations.

So, it is legitimate to ask why it is that Daniel Glaser, one of the delegates to the FATF, when asked to comment upon the latest findings of the FATF Committee, of which he was a constituent member, did not report the findings in an equally clear, unequivocal and open manner.

In responding to a question posed by the New York Sun, Mr Glaser is reported as having given answers that put a wholly different slant to the story. The Sun writer states;

“…American officials saw the FATF's statement as a victory in their financial war against Iran. "It was a great result," America's chief envoy to the task force, Daniel Glaser, said in a phone interview from Paris. "What this action does is call upon all countries in the world to inform their financial institutions of the significant anti-money-laundering financial risk Iran represents. As a result of this action, financial authorities around the world will be requiring their financial institutions to conduct enhanced scrutiny on Iran-related transactions."

Mr. Glaser, who is a deputy assistant secretary of the Treasury for terrorist financing and financial crimes, said the FATF's action was more robust than a warning…”

Daniel Glaser has made no secret of his support for the policies of his US Treasury boss, Stuart Levey, whose openly-stated ambitions are to cripple the Iranian economy and to bring the Iranian nation to its knees by fomenting a popular revolution in that country. Mr Glaser’s telephone conversation with the New York newspaper clearly enabled it to observe;

“…In a move that could cripple Iran's banking sector, the world's premier anti-money-laundering body warned its 34 member states yesterday to advise their banks of the risks of doing business with Iranian banks, citing worries about the Islamic nation's financing of terrorism…while the Paris-based Financial Action Task Force suggests only a warning, the seriousness with which the world's banks will respond to its official statement has the potential to starve Iran of much of its legitimate capital…”

An FATF official who has asked not to be named has confirmed that It is a convention of the FATF that all members of any committee are jointly bound by the agreed statements which are published in their name.

It is not considered to be a proper course of action to make any other statement which might give a different interpretation of what is reported in their name. Individual members are expected to report findings fairly, giving full status to the reported communiques issued by the FATF.

In light of this statement, it is legitimate to ask why Daniel Glaser has found it necessary to be so outspoken, indeed, so triumphalist in his comments. Why did he deliberately choose to ignore any of the positive comments made by the FATF, why has he continued to seek to damage Iran by his comments? He is a co-chair of the committee which is sitting in judgement on Iran and it may be thought that it is entirely improper for him to behave in this way.

His actions could have a significant impact upon the due process within which the FATF itself is seeking to engage. It could conceivably lead the Iranian delegation to legitimately ask whether they are likely to receive a fair hearing, when the co-chairman behaves in this manner, a situation which would paint the FATF in a very bad light indeed.

It is also legitimate to ask which masters Mr Glaser is seeking to serve by behaving in this egregious manner. His actions can not serve the long-term interests of the US, after all, the Bush administration has literally only months left to run. The US Presidential hopeful, Barack Obama has already said that if elected, he will engage in diplomatic discussions with Iran.

It is beginning to look as if Mr Glaser realizes that time is running out for his poisonous policies towards Iran, and those who command his real loyalties, and that his actions betray his true allegiances. It may also be felt, more importantly, that such a realization could bring the FATF itself into disrepute, if it became more widely perceived that influential committee members were intent on serving their own agenda, and not the agreed agenda of the Financial Action Task Force, to which end they have been appointed.

The FATF announced today (28th February 2008) that it does not intend to take any further AML/CTF interventionist action against Iran, following the publication of its earlier notice in October 2007.

The FATF notice states;

“…Since its October 2007 Plenary meeting, the FATF has engaged with Iran and welcomes the commitment made by Iran to improve its AML/CFT regime. Consistent with its Statement on Iran, dated 11 October 2007, the FATF confirms its call to its members and urges all jurisdictions to advise their financial institutions to take the risk arising from the deficiencies in Iran’s AML/CFT regime into account for enhanced due diligence. Iran is encouraged to continue its engagement with the FATF and the international community to address, on an urgent basis, its AML/CFT deficiencies...”

The FATF specifically recognizes therefore the commitment made by Iran to improve its AML regime and encourages it to continue the same. The FATF had the power to impose other sanctions against Iran, but because of its open and transparent cooperation with the FATF, it has chosen not to alter the existing situation, and will continue to work with Iran to remedy all deficiencies.

However, this has not satisfied those officials in the US Government whose ambitions are to harm Iran at every possible opportunity.

Complinet has published a number of articles recently dealing with the impact of US Treasury behaviour on the Iranian banking community, both in the UK and elsewhere.

To recap, the US is deliberately engaged in actions designed to bring significant pressure on other banks and financial institutions, to encourage them to cease any form of financial activity with or for Iranian banks, anywhere in the world.

The source for this policy decision emanates from an office within the US Treasury called the Division of Terrorism and Intelligence, which is headed by Under Secretary Stuart Levey.

Levey has made no secret of his ambitions to bring Iran to its knees, financially and to destabilise its internal economy to such an extent that it will force a popular revolution to overthrow the present government in Iran. A recent quote from the Kansas City Star states;

‘…Washington has boasted that the US and existing UN sanctions, have taken a significant toll on Iran’s economy, particularly on its unemployment and inflation rates and raised pressure on the Government…’

To facilitate his ambitions, Levey and his satraps are always willing to spin news stories and put false and misleading interpretations on any reports which thus enable Iran to be cast in a bad light.

Complinet last reported on the way in which the meeting between the FATF and an Iranian delegation in Paris, in January of this year, was reported in the world media, as the result of a deliberately misleading story issued by the US Treasury.

Now, Levey has issued his own interpretation of the FATF announcement of 28th February 2008. Ignoring the fact that the latest FATF report means that nothing has changed with regard to the Iranian situation, speaking from Dubai where he is openly engaged in seeking to stir up anti-Iranian sentiments in the Gulf region, he deliberately fails to report the fact the FATF noted its recognition of its recent engagement with Iran, and the commitment shown by Iran to improving its AML/CTF position.

However, despite the increasingly bizarre attempts being made by Levey and his subordinates, including Daniel Glaser, to cast Iran in an unfavourable light, in the hope that by so doing, it will influence the UN to impose even further sanctions on Iran, the Iranians will continue to engage with the main body of the FATF in all attempts to ensure that their AML/CTF regime is fully in accordance with FATF requirements.

Daniel Glaser presently leads the US delegation to the FATF, and hisname figured prominently in the previous misleading story which sought to undermine the real reason for the Iranian January meetings with the FATF in Paris. Like Levey, Glaser has been widely quoted as saying that his office is part of the engagement to deter foreign banks from doing business with Iran, and seeking to undermine the Iranian economy. In view of this obvious conflict of interests, Complinet has already questioned his suitability to be a co-chair of the FATF committee which sits in judgement on Iran’s compliance with the FATF requirements.

By adopting these measures of continually attacking Iran publicly, measures which are increasingly being disseminated in the Middle East, the US is painting itself into a corner and is being perceived in much the same light as the boy who cried ‘wolf’ once too often.It has become apparent that many will begin to think that they have protested too much!

On Saturday 16th February 2008, the International Press Agencies all began carrying reports of a ‘secret’ meeting held between US and Iranian officals in Paris earlier in January.

Depending upon which agency you read determined what story you received, but suffice it to say that the majority of the articles carried by the US agencies all placed a major US ‘spin’ on the piece.

Take this as a typical example from the Kansas City Star;

“US secretly met Iran banking officials”

‘…A US official met secretly with Iranian banking officials and senior government aides who oppose punishing the Islamic nation for not doing enough to stop money laundering and terrorism funding…

The United States was represented by Daniel Glaser, the Treasury Department’s deputy assistant secretary for terrorist financing and financial crimes…The meeting was part of the Bush administratiuon’s attempts to ramp up international pressure on Iran to halt atomic activities that could lead to the development of nuclear weapons…’

The way this story is reported places a wholly inaccurate interpretation on the events, and attempts to portray the US’s part in these events in a fictitious light. It is yet another example of the way that the US Treasury continues to disseminate a stream of disinformation about Iranian affairs, particularly Iranian banking and financial affairs, as part of a deliberate US policy to destabilise the Iranian state and its internal economic policies. As the Kansas City Star states quite openly;

‘…Wsahington has boasted that the US and existing UN sanctions, have taken a significant toll on Iran’s economy, particularly on its unemployment and inflation rates and raised pressure on the Government…’

For the record and in the interests of fairness and accuracy, the meeting which took place in Paris at the HQ of the Financial Action Task Force, did so as the result of a specific request from the FATF, in a notice it published in October 2007, in which it expressed its concern over the apparent absence of Iranian laws dealing with anti-money laundering and in which it invited Iran to engage with the FATF, advising that ‘…The FATF looks forward to engaging with Iran to address these deficiencies...’

As a result of this notice, the Iranian Government accepted the FATF request and agreed to attend the meeting in Paris in January to discuss a whole range of issues regarding the state of the development of laws and regulations within Iran for the interdiction of money laundering and terrorist financing.

The meeting was co-chaired by the Italian representative and the US representative, Daniel Glaser. Quite why the US representative was chosen to chair this delicate meeting is not clear, but in light of recent events it may be thought more prudent that he will be replaced at future meetings.

The meeting was reported to be cordial, focused and covered a wide range of issues. The Americans it is reported, played no particularly significant part over any other participant, nor was the meeting anything to do with any policy initiatives on their part, either in Paris or elsewhere. They were merely present at the meeting in the same way as the other FATF representatives, all of whom would have expected the meetings to be kept confidential.

Complinet has recently reported some of the activities being undertaken by agents of the US Treasury in seeking to bring significant economic pressure on the Iranian banking community by threatening other banks and international businesses who have business with Iran that the US will seek to impose draconian penalties on those entities if they continue to do business with Iran.

Complinet has previously identified how the pressure for these unlawful activities has been directed from and by agents of the office of Stuart Levey, US Under Secretary for Terrorism and Financial Intelligence. By focusing on the tactics of pressurizing foreign companies who trade or deal with Iran to drop their business activities, Levey and his team engage in a wide range of activities designed to bring financial and commercial pressure on Iran. The aim is to bring about a revolution from within Iran by so destabilizing the economy of the country that regime change will be effected through a popular revolution.

In view of the proximity of Mr Glaser to Mr Levey, it may be thought reasonable to assert that Mr Glaser is guilty of a significant conflict of interests, and that the Iranians might not unreasonably feel that their own transparent deliberations with the FATF are being undermined by Mr Glaser’s position as co-chair of the meetings, as he is a direct satrap of the very official who is doing everything he can to unfairly undermine the Iranian economy.

It is surely no accident that having observed the willing acceptance by Iran of the FATF invitation to enter multilateral discussions, followed by an even more recent announcement of the passing of the Iranian law outlawing money laundering, that the Americans could easily see that their widely trumpeted allegations of Iranian regulatory non-compliance would now begin to ring a bit hollow.

Hence, the sudden outburst of articles all claiming US initiative for engaging in these recent meetings, and playing up their involvement.

The FATF are engaging in a perfectly proper exercise of their function in encouraging Iran to share with FATF full details of her legislation and other proposed initiatives to engage in a full AML and CTF regime of compliance. In her turn, Iran is complying with the legitimate requests from the FATF, and will be engaging in other meetings when invited in the future.

It would be attractive if the Americans would cease their deliberate attempts to subvert the due process which is taking place, and allow those better-placed to judge the bona-fides of the Iranian procedures, to get on with their work. No-one suggests that the US should not be a party to these deliberations, but in the present circumstances it would be better, and it would certainly look a whole lot fairer to other countries, if Mr Glaser took a back seat.

Wednesday, January 30, 2008

In December 2007, I published an article entitled;

‘…US authorities turn screw on Iranian banks in the UK…’

Since the publication of that article, I have continued to engage in discussions with a wide variety of UK-based businessmen, and the list of persons on the receiving end of US bullying does not stop at financial institutions. Brokerage houses and oil trading companies have also received their visits from the ‘men in the dark blue blazers’, as they were described to me.

The message was the same. Do business of any kind in any currency with Iran, clear their trading requirements, handle their brokerage, engage with their oil handling, open LCs for them, and you will feel the wrath of the US Treasury!

Unable to get any response at all from any official body in the UK, even finding someone who would even return my calls made me begin to realise that there was a lot more to this issue than at first met the eye. It began to resemble nothing so much as the ‘…strange case of the dog in the night-time…’, or the dog that did not bark.

The Sherlock Holmes mystery the "Silver Blaze" was about the theft of an expensive race horse from its stable. During the investigation, Inspector Gregory of Scotland Yard asked Holmes if there was any particular aspect of the crime calling for additional study. Holmes replied "Yes," and pointed to "the curious incident of the dog in the night-time." Inspector Gregory replied, "The dog did nothing in the night-time." Holmes said, "That was the curious incident." In this case, the failure of the dog to bark when the horse was stolen showed the dog knew the thief. This was an important material fact; it considerably reduced the number of suspects, and eventually solved the case.

Growing increasingly suspicious that the British Government might have been turning a deliberate ‘Nelsonian’ blind eye to the wholly unlawful activities of agents of another government, I began to research who these shadowy figures might be and whose interests they might possibly represent.

I have done this with the specific intention of identifying methods and techniques which I would advise British businesses to adopt if they become the recipients of such unlawful conduct in future, as a means of protecting their own commercial interests, and how to respond to these unlawful threats in the future.

Let us be really clear of our terms of reference here. No agent of a foreign government can come to the UK and dictate to any British business how or where that business will carry out its lawful activities. We operate in a highly rule-oriented business environment. The risk-based approach which now determines our every compliance move demands that we engage in a pattern of behaviour which can be scrutinised in the finest detail by our regulatory supervisors. Serious penalties exist for any perceived failure to comply with the new rules and regulations. What is called for is the highest degree of transparency and certainty in the way in which the regulatory environment is enforced.

Receiving unattributable threats of dire commercial consequences from agents of a foreign state, if British banks do not fall into line with their unlawful demands, is not an acceptable state of affairs. Our institutions have every right to expect that the Government will protect them, and once confronted with the evidence of such conduct, should make every move to ensure that the foreign state was appraised, in no uncertain terms, of the displeasure felt by Her Majesty’s Government at such conduct, coupled with stringent demands that such behaviour will cease forthwith.

And what did we get in response when such evidence was laid in front of the relevant Government official? Sadly, we got a predictable response from an aptly-named man, many of whose public outpourings in the money laundering debate leave much to be desired. (See Complinet -Regulus, August 1 2006). Ed Balls made it abundantly clear that he was going to do absolutely nothing about the allegations laid at his door, and, having washed his hands of any responsibility for protecting the British commercial interest, left them to the tender mercies of the American bullies!

So, who are these latter-day ‘new centurions’, these ‘born-again avenging angels of the wrath-to-come?’

Step forward a motley collection of what Sasan Fayazmanes, Chair of the Department of Economics at California State University, Fresno, has described as ‘…individuals who make US foreign policy, particularly the "neoconservatives," and who represent a privileged group of people with a unique and peculiar view of the world. To these "neoconservatives" waging wars against Palestine, Iraq, Lebanon, and possibly Iran and Syria, might appear to be in the "interest" of the US, even though in actuality such policies might be very harmful to the interest of ordinary citizens of the US, particularly in the long-run...’

In an article entitled ‘…The US, Israel and Iran: An Interview with Sasan Fayazmanesh…’, published on 19th March 2007, Ms Fayazmanesh expands her arguments. She states;

‘…When the Bush Administration came to power, more radical members of the Washington Institute, such as Paul Wolfowitz and Richard Perle, took over the formulation and implementation of the White House Middle East policy. These "neoconservatives" were closely linked to the (Israeli) Likud party members, particularly Binyamin Netanyahu. As such, their idea of "containment" of Iran and Iraq went beyond the roundabout way of passing sanctions to ruin the economy of these countries, bringing about discontent, causing revolt and then overthrowing their governments; they advocated a more direct way for "regime change": using the military might of the US to attack these countries. Yet another such individual is Stuart Levey, the present Treasury Department's Under Secretary for Terrorism and Financial Intelligence. Levey has been working zealously to stop foreign banks from dealing with some Iranian banks. In 2005 Stuart Levey gave an address at AIPAC that began with: "It is a real pleasure to be speaking with you today. I have been an admirer of the great work this organization does since my days on the one-year program at HebrewUniversity in 1983 and 1984. I want to commend you for the important work that you are doing to promote strong ties between Israel and the United States and to advocate for a lasting peace in the Middle East." Then he goes on to talk about what his office does and how "[w]e levy economic sanctions to pressure obstructionist regimes, and we have the ability to freeze the assets of wrongdoers."

Mr Levey is the leading influence behind the brave boys who have been running around London issuing their threats against British banks. Mr Levey is proud of his actions and makes little attempt to hide his ambitions. He stated in a speech to the American Enterprise Institute for Public Policy Research on September 8, 2006;

‘…As our government took stock of all of its tools to combat terrorism and the Executive Branch was reorganized after September 11, President Bush, members of his Cabinet, and the Congress recognized that the Treasury Department had unique authorities that could contribute to the fight. This was the genesis of the office I oversee, the Office of Terrorism and Financial Intelligence...’

Mr Levey has learned some very important lessons while in the employ of the US government. He has learned how to position his ambitions and those of his office in such a way that to the uninitiated, they seem almost benign. He has learned how to apply soft words to re-interpret harsh deeds, and he has learned the same lesson that every con-man knows which is ‘if you are going to mislead someone, then do it in the biggest way possible. People will be much more likely to believe you and far less likely to disregard you.

When it comes to the way he interprets his role and that of his officers, he starts predictably, but watch how the message becomes more and more polarised as he gets into his stride;

‘…To maximize the effect, we try to apply these measures in concert with others. Whenever possible, we act with a partner or a group of allied countries. In some cases, we can designate a target at the United Nations. We also have important new regulatory authorities in the United States, such as Section 311 of the USA PATRIOT Act. Section 311 allows us to designate a foreign financial institution or jurisdiction to be of "primary money laundering concern." The impact of that particularly has been more powerful than many thought possible…targeted financial measures warn innocent people not to deal with the designated target. And those who might still be tempted to deal with targeted high risk actors get the message loud and clear: if they do so, they may be next… A second powerful lesson we've learned is that -- particularly in the context of "targeted" sanctions -- we share common interests and objectives with the financial community. Financial institutions want to identify and avoid dangerous or risky customers who could harm their reputations and business. And we want to tell them where those risks lie…’

‘…As I have travelled and met with bank officials abroad, I have learned that even those institutions that are not formally bound to follow U.S. law pay close attention to these targeted actions and often adjust their business activities accordingly. Why? There are two reasons: First, regardless of the underlying law in any particular country, most bankers truly want to avoid facilitating proliferation, terrorism, or crime. These are responsible corporate citizens. Second, avoiding government-identified risks is simply good business. Banks need to manage risk in order to preserve their corporate reputations. Keeping a few customers that we have identified as terrorists or proliferators is not worth the risk of facing public scrutiny or a regulatory action that may impact on their ability to do business with the United States or the responsible international financial community...’

The insouciance Mr Levey adopts is truly breathtaking. He is not telling us how to arrange our business affairs, we are merely ‘adjusting’ our own affairs willingly, even though, as he admits, we are not bound to follow US law. Why are we doing this? Well, apparently we don’t want to keep a few customers ‘…that may impact on our ability to do business with the United States or the responsible international financial community…’

You see, it’s all quite voluntary and absolutely normal because we are ‘…responsible corporate citizens...’

Well, if that’s the case, why do selected Americans deem it necessary to lie so bare-facedly about the present situation in Iran, about the nuclear issue as an example, even when their own intelligence agencies have categorically told them that Iran is not pursuing a nuclear weapon capability? Why do they not provide the asserted evidence of the movement of funds to Hizbollah, which Bank Saderat has repeatedly asked for, and upon which basis they subject Bank Saderat to worldwide calumny. Consider the following statement from Levey;

‘…Iran provides Hizballah with hundreds of millions of dollars each year, which is why I have said that Iran is the central banker of terror. It is remarkable that Iran has a nine-digit line item in its budget to support Hizballah, Hamas, and other terrorist organizations at the expense of investing in the future of its young people...’

‘…As we continue to deal with the challenge presented by Iran's pursuit of a nuclear weapons program, we must also confront its support for terrorism. We have taken several steps to do so this week…’

‘…We have cut off Bank Saderat, from the U.S. financial system. Here is why: This bank, which has approximately 3400 branch offices, is used by the Government of Iran to transfer money to terrorist organizations. For example, since 2001, a Hizballah-controlled organization received $50 million directly from Iran through Saderat. Hizballah uses Saderat to send money to other terrorist organizations as well. Hizballah has used Bank Saderat to transfer funds, sometimes in the millions of dollars, to support the activities of other terrorist organizations such as Hamas in Gaza. We will no longer allow a bank like Saderat to do business in the American financial system, even indirectly…’

George Bush was pushing this same old story this week in the Middle East. If he wants to be believed, why will his agent, Stuart Levey, not provide the evidence to Bank Saderat to back up his assertions? What has he got to hide from the truth being publicly seen. Or is it more likely that his political affiliations make it in their interests to keep up the pressure on Iran but without really telling the truth?

Levey again;

‘…Our actions this week are a sign of the costs that we will impose on the Iranian people if the leadership chooses to remain on its current path of defiance. The regime will end up isolating Iran from the world community, with reputable financial institutions becoming increasingly unwilling to handle Iran's business. The Iranian people deserve better than a government willing to sacrifice their economic well-being to pursue weapons they don't need and policies that result in the deaths of innocent civilians...’

Yet again, Levey knows, because his own intelligence agencies have told him, Iran is not seeking to build weapons, but why let the facts get in the way of a good foreign policy!

So, what can we do if Mr Levey’s blue knights come to our offices and start bullying us with their threats.

The first thing to do is to remember that it is a very serious criminal offence for anyone to make what is called ‘…an unwarranted demand with menaces…’

Under s21(1) of the Theft Act 1968, in English law, a person commits the offence:

If, with a view to gain for himself or another or with intent to cause loss to another, he makes any unwarranted demand with menaces; and for this purpose a demand with menaces is unwarranted unless the person making it does so in the belief:

(a) that he has reasonable grounds for making the demand; and

(b) that the use of the menaces is a proper means of reinforcing the demand.

The Act uses the word "menaces" which is considered wider in scope than "threat" and involves a warning of any consequences known to be considered unpleasant by the intended victim. This covers the spectrum from actual or threatened violence to the victim or others, through damage to property, to the disclosure of information.

It is manifestly clear that the US agents, in making their threats that the US Government will subject a British bank to hostile treatment if they continue to undertake lawful commercial business with Iranian entities, are guilty of such an offence, and the persons making such a threat can be imprisoned for up to 14 years. They cannot possibly have any reasonable grounds for making such a threat, they are acting completely illegally, and the use of the menaces is completely improper.

The loss to be caused does not need to be sustained by the recipient of the threat, it could just as easily be the Iranian counterparty who suffers.

So, at the first sign of any such threat, don’t rise to it or start to protest. It would be wise to just excuse yourself from the meeting, slip out of the room and make an immediate telephone call to your local police office and ask that police officers be sent immediately. State the fact that you are on the receiving end of a serious blackmail threat and that the suspects are still in your offices. You will find the police will get there quickly enough. Let our US friends try and talk their way out of their unlawful conduct to a couple of detectives, and see how far they get.

Alternatively, if the threats you have already sustained are causing you concern about what you can do lawfully or what you might want to do in future, then your institution should be considering undertaking preliminary legal action in the US. I have spoken to US lawyers and they are adamant that no US agency should be conducting themselves in this manner, and that if any such threats have been made, such persons can be called to account in the US courts, and they can be required to identify the evidence upon which they seek to rely to back their assertions of terrorism or criminality.

One New York lawyer of my close acquaintance said to me;

‘…It may have escaped your notice, but the USA is still a country with the rule of law. If these crazies want to threaten law-abiding people, they must not do so without the clearest proof of probable cause and they have to demonstrate the evidence they seek to rely on. They can be required to prove the veracity of that evidence, and in many cases we succeed in demonstrating that it is nothing but hot air…’

I suspect that the mere suggestion that your bank will seek to test the validity of these threats in the US courts will be enough to get these people out of your offices. But what the hell, call the cops first and let them spend a few hours in the cells at Wood Street nick, while their Embassy tries to determine whether they have diplomatic status!

About Me

Having spent my career dealing with financial crime, both as a Met detective and as a legal consultant, I now spend my time working with financial institutions advising them on the best way to provide compliance with the plethora of conflicting regulations and laws designed to prevent and forestall money laundering - whatever that might be! This blog aims to provide a venue for discussion on these and aligned issues, because most of these subjects are so surrounded by disinformation and downright intellectual dishonesty, an alternative mouthpiece is predicated. Please share your views with what is published here from time to time!